Reversal of input tax credit in proportion to exempt supply: specificity of show-cause notice required; order set aside, fresh proceedings allowed wit...
Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
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A provision for warranty computed by reference to past experience and a scientific estimation constitutes a present obligation and therefore an ascertained liability; it does not qualify as an amount set aside for unascertained liabilities and so is not subject to add-back in the computation of book profit under the tax regime's alternate profit measure. Reliance on prior higher court authority supporting allowance where liabilities are reasonably estimable was applied. The addition of the warranty provision to book profit was deleted, and the deletion of the addition under the normal tax provisions was sustained against Revenue's challenge.
A provision for warranty computed by reference to past experience and a scientific estimation constitutes a present obligation and therefore an ascertained liability; it does not qualify as an amount set aside for unascertained liabilities and so is not subject to add-back in the computation of book profit under the tax regime's alternate profit measure. Reliance on prior higher court authority supporting allowance where liabilities are reasonably estimable was applied. The addition of the warranty provision to book profit was deleted, and the deletion of the addition under the normal tax provisions was sustained against Revenue's challenge.
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